Winston Taylor Delivers Defensible Production in Bet-the-Company Dispute with Relativity aiR for Review

How did they do it?

• Deployed generative AI solution Relativity aiR for Review across 72,000 documents under tight deadlines.
• Iteratively refined prompts through close collaboration between merits attorneys and the eDiscovery team, drawing on the specialized expertise of Winston’s eDiscovery attorneys to design defensible, targeted prompts aligned with the claims and defenses in the matter.
• Maintained defensibility through proprietary workflows, incorporating rigorous quality control, sampling, targeted QC, and human oversight – while capturing the efficiency gains achievable with generative AI in discovery.

The Situation: High Stakes and a Compressed Timeline

Winston Taylor (“Winston”) regularly handles complex litigation in jurisdictions where voluminous discovery unfolds under tight timelines. In a recent bet-the-company dispute for a technology client, the initial phase of discovery was especially critical, as it would considerably impact whether the case moved forward. The team had about two weeks to review and produce nearly 100,000 documents while simultaneously supporting a parallel trial.

After initial culling and early data assessment, 72,000 documents were put through Relativity aiR for Review to identify responsive documents for potential production. The data set was unusually complex due to the nature of the client’s business in the technology space. Specifically, it included large volumes of AI-generated content spanning a wide range of topics, many unrelated to the dispute, alongside other materials that were directly relevant.

For the Winston team, isolating the most relevant information within a dataset of this scale required a precise, scalable approach, supported by advanced technology and workflows capable of delivering defensible results and cost predictability.

A Workflow Built Around Strategic Legal Judgment

The team developed a workflow leveraging aiR for Review that kept attorneys closely engaged in defining responsiveness and the core issues in the case. They began with a smaller document set to align on relevance criteria, after which Winston’s eDiscovery attorneys iteratively refined prompts and expanded to larger data populations as confidence in the approach increased.

Human oversight remained central throughout, with targeted QC and sampling ensuring outputs aligned with the team’s legal judgment and expectations.

Even within a dataset where nearly all documents initially appeared “responsive,” the workflow implemented by Winston’s eDiscovery team—leveraging generative AI through aiR for Review—enabled the tool to distinguish meaningfully between materials tied to the claims and defenses at issue and those that were not.

“With a data set this dense and complex, there is a credible risk of over-inclusion or omission. Our strategic approach and layered eDiscovery workflow—powered by aiR for Review—enabled us to strike the right balance: confidence to defend the completeness and accuracy of our production to opposing counsel and, if necessary, the court, while meeting aggressive deadlines and minimizing costs.” Bobby Malhotra, Litigation Partner & Chair, eDiscovery & Information Governance Practice

Understanding the Record While Moving the Case Forward

This approach changed how the case team engaged with the data. Rather than spending time on first-pass review, the case team focused on defining what mattered and validating the underlying results. Through that process, they developed a working understanding of the record as it was being built.

“By leveraging Winston's generative AI workflows powered by aiR for Review, the case team could focus more of their time on strategy rather than document-level triage. The emphasis shifted from ‘Is this responsive?’ to ‘Why does this matter?’—accelerating the kind of strategic analysis that, in traditional workflows, often does not happen until later in the lifecycle of a case.”
Glenn Shubb, Managing Director, WLS and eDiscovery Support Services

Since aiR handled the bulk of first-pass review, the case team could stay focused on defensibility, quality control, and completeness of the production while also shifting more attention to substantive tasks such as filings, meet-and-confers, and trial work.

A Defensible Production

Using aiR for Review, Winston delivered a defensible production within the required timeframe while realizing meaningful cost and time efficiencies. The team retained control over responsiveness and issue coding decisions, significantly reducing the manual burden associated with large-scale review.

This approach also brought the eDiscovery team closer to the substance of the matter, improving coordination and shared understanding across the entire case team.

Most importantly, this matter reflects how Winston approaches data analysis in complex litigation. By utilizing generative AI tools such as aiR for Review in complex litigation, the firm is able to:

• Strategically handle matters with demanding timelines while maintaining a defensible and efficient approach
• Enable attorneys to engage earlier with the record and underlying facts while also focusing on higher-value work
• Deliver a more informed and consistent approach to production, enhancing value and driving stronger outcomes for the client

This approach also reshapes how matters are structured and delivered. By leveraging generative AI to accelerate document review and early-stage data analysis, the team breaks down workflow silos and streamlines legal service delivery—enabling attorneys to focus on the strategic counsel that ultimately drives client outcomes.

The result is a more controlled, informed, and efficient approach, leveraging advanced technology and proprietary Winston firm workflows to handle complex litigation under pressure.

“Generative AI tools such as aiR for Review, combined with Winston’s advanced, defensible workflows, enable our attorneys to assess the record earlier and focus on what matters most – ultimately driving greater value and efficient outcomes for our clients.”
Bobby Malhotra, Litigation Partner & Chair, eDiscovery & Information Governance Practice